Opinion
13614-20 22615-21 23000-21
03-27-2023
PICKENS DECORATIVE STONE, LLC, ECO TERRA 2016 FUND, LLC, TAX MATTERS PARTNER, ET AL Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
These cases involve charitable contribution deductions claimed for the donation of conservation easements. The Internal Revenue Service (IRS or respondent) disallowed the deductions and determined penalties.
On March 17, 2022, the Court issued an Opinion in the case at docket number 13614-20 (T.C. Memo. 2022-22), in which it held that the IRS complied with the requirements of I.R.C. § 6751(b)(1) by securing timely supervisory approval of the penalties asserted in that case.
By Order served December 28, 2022, the Court consolidated these cases for purposes of trial, briefing, and opinion, and assigned jurisdiction of the cases at docket numbers 22615-21 and 23000-21 to the undersigned.
On March 23, 2023, respondent filed a Motion for Partial Summary Judgment in the cases at docket numbers 22615-21 and 23000-21, contending that the IRS complied with the requirements of I.R.C. § 6751(b)(1) by securing timely supervisory approval of the penalties asserted in those cases. Respondent represents that petitioners object to the granting of the Motion.
In consideration of the foregoing, it is
ORDERED that petitioners shall file, on or before April 24, 2023, a Response to the Motion for Partial Summary Judgment.